The results of the Independent Orbiter Assessment (IOA) of the Failure Modes and Effects Analysis (FMEA) and Critical Items Llist (CIL) are presented. The IOA effort first completed an analysis of the Displays and Control hardware, generating draft failure modes and potential critical items. To preserve independence, this analysis was accomplished without reliance upon the results contained within the NASA FMEA/CIL documentation. The IOA results were than compared to the NASA FMEA/CIL baseline with proposed Post 51-L updates included. A resolution of each discrepancy is provided through additional analysis as required. The results of that comparison for the Orbiter D and C hardware are documented.